Chapter 1: Introduction 

1. Introduction 

This document is a revision of the 1987 Comprehensive Conservation Plans (Plan) for the 

management of the Koyukuk and Northern Unit Innoko (locally referred to as the Kaiyuh or 

Kaiyuh Flats) and Nowitna National Wildlife Refuges (the three refuges combined will 

hereafter be referred to as Refuge or individually as the Koyukuk, Northern Unit Innoko, or 

Nowitna). The two plans have been combined into one Plan. This revised Plan replaces the 

management direction for the Refuge described in the Koyukuk and Northern Unit Innoko 

National Wildlife Refuge Final Comprehensive Conservation Plan/Environmental Impact 

Statement/Wilderness Review October 1987 and Nowitna National Wildlife Refuge 

Comprehensive Conservation Plan/Environmental Impact Statement/ Wilderness 

Review/Wild River Plan Final 1987 and associated records of decision. 

The U.S. Fish and Wildlife Service (Service) administers approximately 7,302,000 acres of land 

and water in western interior Alaska as the Koyukuk and Northern Unit Innoko and Nowitna 

National Wildlife Refuges (Figure 1-1). This chapter provides background information that 

establishes the framework used to develop this document, including (1) the purpose of and 

need for the Plan; (2) an overview of the Refuge, including historical perspective and refuge 

establishment; purposes, vision, and goals of the Refuge; and the environmental setting; (3) 

the legal context of refuge management; and (4) the planning process, including identification 

of significant planning issues addressed in the Plan. 

1.1 Purpose of and Need for Action 

The purpose of this planning action is to revise the Koyukuk and Nowitna plans originally 

developed and adopted in 1987. The Koyukuk and Nowitna Plans provide broad policy 

guidance and establish management direction for the Refuge. The Plan defines long-term 

goals and objectives toward which refuge management activities are directed and identifies 

which uses may be compatible with the purposes of the Refuge and mission of the National 

Wildlife Refuge System (Refuge System or System). Conservation plans are viewed as 

dynamic documents, requiring periodic review and updating. 

Federal statute, specifically section 304(g) of the Alaska National Interest Lands 

Conservation Act of 1980, as amended, 16 U.S.C. 140hh-3233, 43 U.S.C. 1602-1784 (ANILCA), 

directs the Secretary of the Interior to prepare, and from time to time revise, a “. . . 

comprehensive conservation plan . . . for each refuge (in Alaska) . . .” 

Following guidance found in ANILCA and other federal laws—primarily the National 

Wildlife Refuge System Administration Act of 1966, as amended by the National Wildlife 

Refuge System Improvement Act of 1997, 16 U.S.C. 668dd-668ee (Refuge Administration 

Act); and the National Environmental Policy Act of 1969, as amended, 42 U.S.C. 4321-4347 

(NEPA) as implemented by the Council on Environmental Quality’s (CEQ) Regulations for 

Implementing the Procedural Provisions of NEPA, 40 CFR 1500-1508—the Service revised 

the Koyukuk and Nowitna National Wildlife Refuge plans to provide direction for 

management of the Refuge for the next 15 years. Revising the Plans allows the Service to 

accomplish the following: 

Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 1-1 
Chapter 1: Introduction 

 Update management direction related to national and regional policies and guidelines 

implementing federal laws governing refuge management; 

 Incorporate new scientific information on refuge resources; and 

 Reevaluate current refuge management direction based on changing public demands 

for use of the Refuge and its resources. 

This document is the Final Koyukuk Nowitna Refuge Comprehensive Conservation Plan. It 

describes the management of the Refuge for the next 15 years. 

In addition to the preceding requirements, a comprehensive conservation plan serves to do the 

following: 

 Ensure that the purposes of the Refuge and the mission of the Refuge System are 

being fulfilled; 

 Ensure that national policy direction is incorporated into the management of the 

Refuge; 

 Ensure that opportunities are available for interested parties to participate in the 

development of management direction; 

 Provide a systematic process for making and documenting decisions about refuge 

resources; 

 Establish broad management direction for refuge programs and activities; 

 Provide continuity in refuge management; 

 Provide a basis for budget requests; and 

 Provide a basis for evaluating accomplishments. 

1.2 Planning Context 

The Refuge is part of the National Wildlife Refuge System. The Service places an emphasis 

on managing individual refuges in a manner that reflects national priorities of the Refuge 

System. As a result, the final plan must contribute to meeting the mission and goals of the 

entire Refuge System. 

1.2.1 The U.S. Fish and Wildlife Service 

Part of the Department of the Interior, the Service is the principal federal agency responsible 

for conserving, protecting, and enhancing the nation’s fish, wildlife, plants, and their habitats. 

In addition to the Refuge System, the Service operates national fish hatcheries, fishery 

resource offices, and ecological services field stations. The service enforces federal wildlife 

laws, administers the Endangered Species Act, manages migratory bird populations, restores 

nationally significant fisheries, conserves and restores wildlife habitat such as wetlands, and 

helps foreign governments with their conservation efforts. It oversees the Federal Aid in 

Wildlife Restoration program, which distributes to state fish and wildlife agencies hundreds of 

millions of dollars derived from excise taxes on fishing and hunting equipment. 

The mission of the U.S. Fish and Wildlife Service is: 

1-2 Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 1-3

Working with others to conserve, protect, and enhance fish, wildlife, and plants and their 

habitats for the continuing benefit of the American people (602 FW 1.6W). 

1.2.2 The National Wildlife Refuge System 

The National Wildlife Refuge System comprises more than 96 million acres of federal lands, 

encompassing more than 545 national wildlife refuges, thousands of small wetlands, and other 

special management areas. Refuge System lands are located in all 50 states and the 

territories of the United States. 

The Refuge System was created to conserve fish, wildlife, plants, and their habitats. This 

conservation mission includes providing Americans with opportunities to participate in 

compatible wildlife-dependent recreation, including fishing and hunting, on Refuge System 

lands and to better appreciate the value of and need for fish and wildlife conservation. 

Alaska contains 16 national wildlife refuges (see Figure 1-1). These refuge lands contain a 

wide range of habitats with varied terrain, including mountains, glaciers, tundra, grasslands, 

wetlands, lakes, woodlands, and rivers. Together, the 16 refuges comprise 76.8 million acres 

and constitute about 80 percent of the National Wildlife Refuge System. 

Figure 1-1. Refuge location within Alaska 
Chapter 1: Introduction 

Figure 1-2. Refuge location within the region 

1-4 Koyukuk/Nowitna National Wildlife Refuge Revised Compre
Chapter 1: Introduction 

The mission of the Refuge System is: 

To administer a national network of lands and waters for the conservation, management, 

and, where appropriate, restoration of the fish, wildlife, and plant resources and their 

habitats within the United States for the benefit of present and future generations of 

Americans [Refuge Administration Act; 16 U.S.C. 668dd(a)(2)]. 

1.2.3 Principles for Managing the National Wildlife Refuge System 

The Refuge System Administration Act, as amended, states that each refuge shall be managed 

to fulfill both the mission of the Refuge System and the purposes for which the individual 

refuge was established. It requires that any use of a refuge be a compatible use (one that will 

not materially interfere with or detract from fulfillment of the mission of the System or the 

purposes of the refuge, based on sound professional judgment). 

The 1997 amendments to the Refuge Administration Act identified a number of principles to 

guide management of the Refuge System: 

 Conservation of fish, wildlife, and plants, and their habitats within the Refuge System; 

 Maintenance of biological integrity, diversity, and environmental health of the Refuge 

System; 

 Carrying out the mission of the Refuge System and the purposes of each refuge 

(except that if a conflict exists, refuge purposes are protected first); 

 Effective coordination, interaction, and cooperation with adjacent landowners and 

state fish and wildlife agencies; 

 Maintenance of adequate water quantity and water quality to meet refuge and system 

purposes and acquisition of necessary water rights under state law; 

 Recognition of hunting, fishing, wildlife observation and photography, and 

environmental education and interpretation as the priority general public uses of the 

Refuge System; 

 Provision of opportunities for compatible priority wildlife dependent public uses within 

the Refuge System; 

 Provision of enhanced consideration for priority wildlife-dependent uses over other 

public uses in planning and management within the Refuge System; 

 Provision of increased opportunities for families to experience compatible wildlifedependent recreation, particularly traditional outdoor activities such as fishing and 

hunting; and 

 Monitoring of the status and trends of fish, wildlife, and plants within each refuge. 

To maintain the health of individual refuges, and the National Wildlife Refuge System as a 

whole, managers must anticipate future conditions. Managers must endeavor to avoid adverse 

impacts and take positive actions to conserve and protect refuge resources. Effective 

management also depends on acknowledging resource relationships and acknowledging that 

refuges are parts of larger ecosystems. Refuge managers work together with partners—

including other refuges, federal and State agencies, tribal and other governments, Native 

organizations and entities, and nongovernmental organizations and groups—to protect, 

conserve, enhance, or restore all native fish, wildlife, plants, and their habitats. 

Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 1-5 
Chapter 1: Introduction 

1.3 Legal and Policy Context and State Coordination 

The Service manages national wildlife refuges pursuant to various legal and administrative 

requirements. Management of the Refuge is dictated, in large part, by ANILCA, which 

established the Refuge and identified the purposes for which it was established. However, 

numerous other laws, treaties, executive orders, and agreements with other parties (e.g., the 

State of Alaska) also guide management of the Refuge. 

1.3.1 Legal Guidance 

Operation and management of refuges throughout the Refuge System are influenced by a 

wide array of laws, treaties, and executive orders and the regulations and policies developed to 

implement them. Among the most important are the Refuge System Administration Act as 

amended by the Refuge System Improvement Act, the Refuge Recreation Act, the Alaska 

Native Claims Settlement Act (ANCSA), and the Endangered Species Act. Brief descriptions 

of these and other pertinent legal documents that influence management of the Refuge are 

found in appendix A. 

For national wildlife refuges in Alaska, ANILCA, as amended, provides key management 

direction. ANILCA sets forth the purposes for each refuge and provides administrative 

direction for management of the refuges, including requiring development of comprehensive 

conservation plans for each refuge. Additional provisions authorize studies and programs 

related to wildlife and wildland resources, subsistence opportunities, and recreation and 

economic uses. How ANILCA influences management of the Refuge is reflected throughout 

this document. 

After reviewing the requirements for Wilderness reviews, we determined that the 

comprehensive planning requirements of section 304(g) of ANILCA have been satisfied by the 

Wilderness recommendation of the 1987 Plans. 

A similar approach was taken with Wild and Scenic River reviews. We determined that we 

would meet the intent of the Wild and Scenic Rivers Act of 1968 by focusing our efforts on 

describing river values and providing direction regarding the protection of these values. 

Wilderness values and river-related values are discussed in chapter 3, sections 3.5 and 3.6 of 

this Plan. Programs and actions to protect all refuge-related values are discussed in the 

management direction sections of chapter 2. 

1.3.2 Policy Guidance 

Programmatic guidance and policy documents provide additional direction for management of 

national wildlife refuges throughout the Refuge System. These documents include the U.S. 

Fish and Wildlife Service Manual, director’s orders, national and regional policy issuances, 

handbooks, director’s memorandums, and regional directives. Although it is not practical to 

provide information about all of these documents in this Plan, they are critical to management 

of the Refuge and the Refuge System as a whole. Much of the management direction 

described in chapter 2, and in other parts of this Plan, is derived from these programmatic and 

policy documents. 

1-6 Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 1-7

Several of these documents direct that an ecosystem approach be used in refuge management. 

We must consider the health of the entire ecosystem when managing the Refuge. This 

concept requires close coordination with others. Appendix A provides a brief description of 

this concept and of several of the national and regional management plans and programs that 

were considered during the development of this Plan. Other key policies, such as the 

compatibility policy, are described in later chapters, as they provide guidance in this Plan. 

1.3.3 Coordination with the State of Alaska 

The Alaska Department of Fish and Game (ADF&G) has primary responsibility for managing 

Alaska’s fish and resident wildlife populations. The Service has primary responsibility for 

management of migratory birds, endangered species, and other species mandated by federal 

law. On all refuge lands, the Service and ADF&G share a concern for all fish and wildlife 

resources and their habitats, and both are engaged in fish and wildlife conservation, 

management, and protection programs. In 1982, the Service and ADF&G signed a Master 

Memorandum of Understanding that defines the cooperative management roles of each 

agency and sets the framework for cooperation between the two agencies (see appendix B). 

The State of Alaska (State) establishes fishing, hunting, and trapping regulations at the 

direction of the Alaska Boards of Fisheries and Game. These regulations apply to federal 

public lands unless superseded by federal regulations. If Service restrictions on hunting were 

needed, they would be done through a rule-making or through closures or restrictions under 

50 CFR 36.41. The State is divided into 26 game management units (GMUs); see Figure 1-3. 

Management objectives are developed for populations within each GMU. The Refuge is within 

GMU 21 and 24. The ADF&G management objectives for big-game and fish populations on 

the Refuge are described in chapter 3. 

The Alaska Department of Natural Resources (DNR) and its divisions are key management 

partners. DNR manages all State-owned land, water, and surface and subsurface resources 

except for fish and wildlife. The DNR - Division of Mining, Land, and Water manages the 

State’s water and land interests, including any within national wildlife refuges in Alaska. These 

interests will become increasingly significant in the next 15 years, especially with regard to 

water rights, navigable waters, ownership of submerged lands, and rights-of-way over refuge 

lands. The division is responsible for development of plans for management of State lands (e.g., 

the plan currently being developed). 

Additional information about key State programs is provided in appendix B. 
Chapter 1: Introduction 

 Figure 1-3. Refuge land status, GMUs, and CUA 

1-8 Koyukuk/Nowitna National Wildlife Refuge Revised Compre
Chapter 1: Introduction 

1.4 Refuge Purposes and Vision Statement 

1.4.1 Purposes of Koyukuk National Wildlife Refuge 

Section 101(b) of ANILCA identifies purposes for all conservation system units in Alaska 

and states: 

“It is the intent of Congress in this Act to preserve unrivaled scenic and geological values 

associated with natural landscapes; to provide for the maintenance of sound populations of, 

and habitat for, wildlife species of inestimable value to the citizens of Alaska and the Nation, 

including those species dependent on vast relatively undeveloped areas; to preserve in their 

natural state extensive unaltered arctic tundra, boreal forest, and coastal rainforest 

ecosystems; to protect the resources related to subsistence needs; to protect and preserve 

historic and archeological sites, rivers, and lands, and to preserve wilderness resource values 

and related recreational opportunities, including but not limited to hiking, canoeing, fishing, 

and sport hunting, within large arctic and subarctic wild lands and on free-flowing rivers; and 

to maintain opportunities for scientific research and undisturbed ecosystems.” 

Section 302(5) (B) of ANILCA states: 

“The purposes for which the Koyukuk National Wildlife Refuge is established and shall be 

managed include— 

(i) to conserve fish and wildlife populations and habitats in their natural diversity 

including, but not limited to waterfowl, raptors and other migratory birds, 

furbearers, moose, caribou (including participation in coordinated ecological studies 

and management of the Western Arctic caribou herd), furbearers, and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to 

fish and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) 

and (ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity 

within the refuge.” 

The purpose of the Koyukuk Wilderness is to secure an enduring resource of wilderness, to 

protect and preserve the wilderness character of the area as part of the National Wilderness 

Preservation System, and to administer the area for the use and enjoyment of the American 

people in a way that will leave it unimpaired for future use and enjoyment as wilderness. 

Major purposes for which the Innoko Refuge was established and shall be managed were set 

forth in section 302(3) (B) of ANILCA. Only the first purpose differs from those for the 

Koyukuk Refuge. This purpose is: 

Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 1-9 
Chapter 1: Introduction 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including but not limited to waterfowl, peregrine falcons, other migratory 

birds, black bear, moose, furbearers, and other mammals, and salmon. 

Major purposes for which the Nowitna Refuge was established and shall be managed were set 

forth in section 302(6) (B) of ANILCA. Only the first purpose differs from those for the 

Koyukuk Refuge. This purpose is: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including but not limited to trumpeter swans, white-fronted geese, canvasbacks 

and other waterfowl and migratory birds, moose, caribou, martens, wolverines, 

and other furbearers, salmon, sheefish, and northern pike. 

The lower 223 miles of the Nowitna River is managed as a Wild River under the Wild and 

Scenic Rivers Act. This segment of the river was recognized for its outstandingly remarkable 

scenic, geologic, wildlife, historic, and recreational values. 

1.4.2 Refuge Vision Statement 

Service Planning Policy (Service Manual 602 FW 3.4G) directs each national wildlife refuge to 

develop a vision statement for the refuge during the comprehensive conservation planning 

process. A vision statement is “[a] concise statement of what the planning unit (refuge) could 

be, or what we could do, in the next 10 to 15 years, based primarily upon the Refuge System 

mission and specific refuge purposes, and other relevant mandates (Service Manual 602 FW 

1.6S).” The following statement provides this vision for the Refuge: 

The National Wildlife Refuges in the Koyukon region of Alaska encompass a vast area of 

boreal forest, wetlands, lakes and rivers that is home to an abundance of waterfowl, songbirds, 

mammals, and fish. An experience of solitude in this intact ecosystem imparts the sense that 

this place is completely untouched by man. And yet, the land is thoroughly known and 

essential to people whose lives are intertwined with its bounty. We use our understanding of 

the respect, value, and love of this place by the people who live in, use, or simply treasure this 

wild land and sound biological research and monitoring to ensure proper stewardship of the 

Koyukuk, Northern Unit Innoko, and Nowitna National Wildlife Refuges.

1.5 Refuge Overview 

1.5.1 Historical Perspective and Refuge Establishment 

On December 2, 1980, President Jimmy Carter signed into law the Alaska National Interest 

Lands Conservation Act. Section 302 of this act established the Innoko, Koyukuk, and 

Nowitna refuges as part of the National Wildlife Refuge System. 

1.5.2 Physical Environment 

The Koyukuk Refuge contains 4,500,000 acres. The southern boundary is located seven miles 

north of Galena, which is located on the Yukon River. The refuge is situated in a circular 

floodplain basin of the Koyukuk River just north of its confluence with the Yukon River. The 

variably forested floodplain is surrounded by the Nulato Hills on the west, the Purcell Mountains 

1-10 Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

and Zane Hills on the north, Galena Mountain on the east, and the Yukon River on the south. 

Numerous lakes, sloughs, and rivers are prominent across the refuge with the Koyukuk River 

being the dominant natural feature. 

The Northern Unit Innoko contains 751,000 acres. It is located southeast of the village of 

Nulato situated in an area known locally as the Kaiyuh or Kaiyuh Flats. The refuge lies within 

an extensive floodplain with over 80 percent of the area being either water or wetlands and is 

bounded on the north and west by the Yukon River and on the east and south by the Kaiyuh 

Mountains. 

The Nowitna Refuge contains 2,051,000 acres and is located less than two miles east of Ruby 

and south of the Yukon River. The refuge is bounded by the Yukon River on the north, the 

Boney Creek Bench lands on the east, the upper slopes of the Nowitna River Canyon on the south, 

and the Poorman Road Mountains on the west. 

The Koyukuk and Northern Unit Innoko, along with the Nowitna, are managed out of the 

Galena office. 

1.5.3 Biological Resources 

Black spruce forest with inclusions of tundra, willow-dominated brush fields, and muskeg 

dominates the vegetation across the Koyukuk. White spruce is common along the major rivers. 

The combination of wetlands and terrestrial habitats supports a relatively high population of 

moose, furbearers, waterfowl, and fish. These resources are important to local subsistence users. 

The Koyukuk Wilderness encompasses the Nogahabara sand dunes. 

Wetlands dominate the landscape of the Northern Unit Innoko. Black and white spruce and low 

shrubs dominate the vegetation. Waterfowl utilize the refuge for nesting and brood rearing. 

Moose and especially beaver are common to the area. Northern pike are common to most lakes, 

ponds, and streams. 

The Nowitna Refuge consists primarily of black spruce forests, wetlands, ponds and streams, 

bench lands, and foothills. The Nowitna River floodplain is the Refuge’s most productive area. 

It supports the majority of the Refuge’s waterfowl, furbearers, wolves, moose, and bear. The 

Nowitna River is a congressionally designated Wild River. It forms a wide, meandering floodplain 

except for the Nowitna River Canyon. 

A fire disturbance regime dominates all three refuges. 

1.5.4 Human Uses 

The majority of the use on the refuges is by local residents from the surrounding communities 

of Galena, Hughes, Huslia, Kaltag, Koyukuk, Nulato, Ruby, and Tanana for subsistence 

activities. Ten outfitters, guides, and transporters currently operate on the Refuge annually. 

The Kaiyuh Flats has a rich history of local Athabascan use. 

Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 1-11
Chapter 1: Introduction 

1.6 Special Values of the Refuge 

Section 304(g) of ANILCA directs the Secretary of the Interior to identify and describe 

“special values of the refuge, as well as any other archaeological, cultural, ecological, 

geological, historical, paleontological, scenic, or wilderness values of the refuge.” The following 

special values have been identified for Koyukuk and Northern Unit Innoko Refuges. 

1.6.1 Mosaic of Early Successional Habitats 

The incidence of fire on the Refuges is one of the highest in Alaska. The Refuge’s fire return 

interval is 275 years based on the past 57 years of fire history. The mosaic of seral vegetation 

stages reflects the strong influence of fire. Early seral habitats are present over a large area 

of the Refuge. Ice scouring in the floodplain has created a significant amount of early seral 

stage willow, which provides the major source of winter moose browse. The abundance of such 

habitats, which are dominated by herbaceous and shrub species, supports a relatively high 

density of moose and other wildlife in some areas. 

1.6.2 Diverse System of Streams, Lakes, and Wetlands 

The relatively natural free-flowing waters of the Refuge result from an ecological process that 

creates a mosaic of continuously evolving habitat and maintains a diversity of fish and wildlife 

populations. These free-flowing waters recharge lakes and wetlands during periods of 

flooding and move sediment and nutrients throughout the riparian area. The Koyukuk Refuge 

was created in large part to protect the wetlands adjacent to the Koyukuk River and its 

tributaries. These wetlands include an estimated 15,000 lakes and 5,500 miles of rivers and 

streams. 

1.6.3 Kaiyuh Flats 

This area is unique because over 80 percent of the refuge is water or wetlands. It is one of the 

few areas along the Yukon River that has a water level that fluctuates with the rise and fall of 

the Yukon River. The area is widely used by local Athabascan people and has a very rich 

history. 

1.6.4 Nogahabara Sand Dunes 

The Nogahabara sand dunes are one of the largest active sand dunes in Alaska. It is a small 

portion of a Pleistocene dune field that is now mostly inactive. The active area is about 16,000 

acres and consists primarily of dunes 20 to 50 feet high and 100 feet or more in length. The 

dunes form the central core of the Koyukuk Wilderness, which encompasses 400,000 acres. 

1.6.5 Salmon Habitat 

The Koyukuk River and its major tributaries, the Gisasa, Kateel, Huslia, and Dulbi rivers, 

provide migration corridors and spawning and rearing habitat for chum salmon. A smaller 

population of Chinook and coho salmon use these rivers for migration and spawning and 

rearing habitat. Chinook, coho, and chum salmon, whitefish, sheefish, and northern pike 

comprise an important subsistence fisheries resource. 

1-12 Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

1.6.6 Boreal-nesting White-fronted Goose Habitat 

The Koyukuk and Northern Unit Innoko provide significant nesting, rearing, and molting 

habitat for white-fronted geese. 

1.6.7 Trumpeter and Tundra Swan Habitat 

Trumpeter and tundra swan range overlaps on the Koyukuk Refuge. The Refuge lies at the 

northwestern limit of trumpeter swan habitat. Swans of both species nest in significant 

numbers on the Refuge, making the area ecologically unique. The population of both species 

has been steadily increasing. 

1.6.8 Subsistence Harvest on the Koyukuk and Northern Unit Innoko 

One of the purposes for the refuges set forth in ANILCA is to provide the opportunity for 

continued subsistence use by local residents. Residents of nearby villages continue to depend 

upon the Refuge for their subsistence needs. Moose and salmon comprise the most used refuge 

resources. Trapping provides additional income to some individuals but not to the degree it did 

two decades ago. Annually, a variety of berries are picked, and some medicinal plants are 

harvested. The Refuge issues up to four special use permits for cabin logs each year. This 

subsistence-based socioeconomic system characteristic of the Refuge is dynamic. The system 

depends on the continuing relationship between subsistence users and the resources used. 

1.6.9 Caribou Herds 

The Western Arctic caribou herd is the largest caribou herd in Alaska, which numbered an 

estimated 377,000 animals in 2007. The Koyukuk Refuge is part of the herd’s traditional 

caribou range. The Galena Mountain caribou herd utilizes the Koyukuk for winter habitat. Its 

population is estimated to be between 150 and 200 animals. 

The following special values have been identified for the Nowitna Refuge.

1.6.10 Nowitna River 

The Nowitna River is a congressionally designated Wild River. The meandering nature of the 

Nowitna River has created a diversity of terrestrial and aquatic habitats that are very 

productive areas for waterfowl, moose, furbearer, and northern pike. The river changes 

courses by forming and then cutting through oxbows, creating isolated oxbow lakes that are 

ideal nesting areas for swans, geese, and ducks. River erosion destroys mature terrestrial 

habitat on the outside of bends and forms—on the inside of bends—new gravel and sand bars 

that are quickly vegetated by willows, sedges, grasses, and forbs. All seral stages of 

terrestrial and aquatic habitats are represented in the Nowitna River floodplain. Spring 

flooding enriches the oxbow lakes and sloughs with nutrients and carbonates from the 

limestone bedrock in the river’s canyon area. As a result, the lakes are less acidic and more 

productive than most other Alaskan waters. 

Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 1-13
Chapter 1: Introduction 

1.6.11 Sheefish 

The population of sheefish found in the Nowitna River is currently being studied to unravel all 

of the unknowns surrounding this species. The population is anadromous, following a sinuous 

path before heading to the Yukon River. Sport fishing for trophy-size sheefish is an 

established activity on the Nowitna River. 

1.6.12 Agates 

The gravel bars on the upper Nowitna River are rich in agates. Agate hunting is a popular 

visitor activity there. The agates are believed to have originated in a layer of volcanic flows 

along the Nowitna River upstream from its confluence with the Sulukna River. 

1.6.13 Palisades 

The Palisades site on the Yukon River is comprised of a series of silt bluffs rising up to 300 

feet above the river and extending for about seven miles along the river. The bluffs are 

commonly referred to as the Boneyards because fossil remains of Pleistocene mammals 

periodically emerge from the eroding frozen silt. Preserved within the bluffs are layers of 

prehistory reaching back at least two million years (Matheus et al. 2003). The site is 

unmatched in Alaska for paleo-environmental study. The bluffs contain one of the oldest 

series of datable volcanic ash layers in the State. It preserves at least three buried forest 

layers representing interglacial periods within the early, middle, and late Pleistocene. The 

presence of datable layers, interspersed with buried ice wedges and abundant fossil plant and 

animal remains, provides researchers with detailed information about local past environments. 

Fossil collection is prohibited other than by researchers working under permit. 

1.6.14 Boney Creek Dissected Bench Land Formation 

This landscape feature consists of dissected bench lands and is unique to interior Alaska. 

The area has a canyon-land landscape with flat-topped mesa or plateau-like areas dissected 

by small parallel streams. The bench lands consist of vegetated sand dunes that have been 

modified by erosion and show a northeast-southwest orientation. The unusual drainage 

patterns are at various angles to the orientation of the dunes and seem to be unrelated to 

any underlying bedrock. 

1.6.15 Waterfowl 

The refuge contains very productive areas for trumpeter swans, white-fronted geese, and 

ducks. 

1.6.16 Furbearers 

The abundance of mature trees provides some of the best marten habitat found in Alaska. 

Beaver are abundant, particularly in the oxbow lakes in the Nowitna River lowlands and in 

grass lakes lying along the Yukon River. 

1-14 Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

1.7 Planning Requirements 

Section 304(g) of ANILCA directs that comprehensive conservation plans be developed for 

each refuge. It also specifies procedures to follow while developing these plans. 

The following must be identified and described prior to developing a plan for any refuge: 

 the populations and habitats of the fish and wildlife resources of the refuge; 

 the special values of the refuge and any other archeological, cultural, ecological, 

geological, historical, paleontological, scenic, or wilderness values of the refuge; 

 areas within the refuge suitable for use as administrative sites or visitor facilities, or 

for visitor services, as provided for in ANILCA sections 1305 and 1306; 

 present and potential requirements for access with respect to the refuge, as provided 

for in ANILCA title XI; and 

 significant problems which may adversely affect the populations and habitats of fish 

and wildlife identified. 

Each comprehensive conservation plan shall: 

 be based upon the identifications and the descriptions in the previous planning 

requirements— 

(i) designate areas within the refuge according to their respective resources 

and values; 

(ii) specify the programs for conserving fish and wildlife and the programs 

relating to maintaining the values of the refuge that are proposed to be 

implemented within each area; and 

(iii) specify the uses within each such area that may be compatible with the 

major purposes of the refuge; and 

 set forth those opportunities which will be provided within the refuge for fish and 

wildlife- oriented recreation, ecological research, environmental education, and 

interpretation of refuge resources and values, if such recreation, research, education, 

and interpretation is compatible with the purposes of the refuge. 

While preparing the plans, the Service is required to ensure adequate interagency 

coordination and public participation. Any interested and affected parties such as State 

agencies, Native corporations, local residents, and political subdivisions that would be affected 

by decisions in the plan must be provided meaningful opportunities to present their views. 

Prior to adopting a plan, the Service will issue notice of its availability in the Federal Register, 

make copies available in regional offices of the Fish and Wildlife Service throughout the U.S., 

and provide an opportunity for public review and comment. 

1.8 The Planning Process for the Refuge 

This section describes the process used to develop the Final Comprehensive Conservation 

Plan. The process is consistent with the planning requirements specified in section 304(g) of 

ANILCA; the Refuge System Administration Act, as amended by the National Wildlife 

Refuge System Improvement Act; the Service’s planning policy (602 FW 1 and 3); the 

National Environmental Policy Act (42 U.S.C. 4321-4347); and the Council on Environmental 

Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 1-15
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Quality’s Regulations for Implementing the Procedural Provisions of the National 

Environmental Policy Act (40 CFR 1500–1508). The Service used an eight-step planning 

process to revise the Refuge Plan: 

1) Design the planning process (preplanning) 

2) Initiate public involvement and scoping 

3) Determine significant issues 

4) Develop and analyze alternatives 

5) Prepare draft comprehensive conservation plan and environmental assessment 

6) Prepare and adopt a final plan by issuing a Finding of No Significant Impact or 

proceed in the development of an environmental impact statement 

7) Implement the plan and monitor and evaluate it 

8) Review and revise the plan 

1.8.1 Design the Process 

In 2007, the Service began reviewing the Koyukuk and Northern Unit Innoko and the 

Nowitna National Wildlife Refuge Plans to determine how they should be revised. The 

Service found that, in most cases, on-the-ground management actions were meeting refuge 

objectives. However, some management direction needed to be updated. New laws (such as 

the Refuge System Improvement Act), new regulations and policies, and other changes (such 

as federal management of subsistence on Alaska refuges) needed to be included in the Plan. 

The Service decided to combine the refuge Plans into one because the three refuges are 

administered out of the same office. 

The Service then identified all relevant laws, regulations, policies, and other direction that 

would have to be considered during revision of the Plan. These were discussed in the legal and 

planning context sections earlier in this chapter, and additional detail can be found in appendix 

A. The Service also reviewed data available on refuge resources and uses and identified some 

areas in which additional work was required. 

1.8.2 Initiate Public Involvement and Scoping 

This step informed people that the Plan revision process was beginning and that we were 

soliciting ideas on what should be addressed in the revision. Formal scoping began with 

publication of the Notice of Intent to revise the Koyukuk and Northern Unit Innoko and the 

Nowitna National Wildlife Refuge Comprehensive Conservation Plans and prepare an 

environmental assessment (EA), which was published in the Federal Register on October 9, 2007 

(Vol. 72 No. 194, pp. 53343-53344). 

In November 2007, a newsletter announcing the revision and seeking comments was mailed to 

numerous individuals and organizations on the mailing list developed by the regional office. 

Copies of the newsletter were also sent to all post office box holders in Galena. The newsletter 

contained information about the Refuge, described issues identified by the refuge staff and a 

group of village leaders, and provided an opportunity for the public to identify other issues 

that should be addressed during the revision of the Plan. 

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Public meetings to gather input were held in eight communities adjacent to and lying within 

the Refuge. Attendance at these meetings ranged from 8 to 26 individuals. Individuals and 

organizations provided 60 written and oral comments. Topics identified by the public included 

wildlife populations; competition between local and non-local users for refuge resources; the 

public feeling not listened to; being sensitive to cultural traditions; future public use; climate 

change; the cabin permitting policy; timber harvest; mining, oil and gas leases; the effects of 

off-refuge mining activities on refuge land; and future development on and off the Refuge. 

1.8.3 Determine Significant Issues 

The planning team reviewed the issues raised by the public, refuge staff, other Service 

divisions, tribal governments, and the State to determine the significant planning issues to be 

addressed in the revised Plan. Significant issues are those that are within the range of control 

of the Refuge and may be handled differently in the alternatives. Eight issues were identified. 

Section 1.9 describes the process used to identify the significant planning issues. 

1.8.4 Develop and Analyze Alternatives 

Following the determination of significant planning issues in January 2008, the planning team 

developed a set of draft alternatives for management of the Refuge. A planning update was sent 

to over 300 individuals, State agencies, and local government agencies in the affected area asking 

for comments, suggestions, and questions. Sixty comments were received, and the refuge staff 

made minor revisions to the draft alternatives. The final set of alternatives along with an analysis 

of the environmental effects was presented in the draft revised Plan. 

1.8.5 Prepare Draft Plan and Environmental Assessment 

The purpose of this step was to produce the draft revised Plan. This document described two 

alternatives (including the current management) for managing the Refuge over the next 15 

years. It included an analysis of the potential impacts of implementing each alternative and 

described how the Service determined its preferred alternative (Alternative B). Also included 

was a description of the management that would remain the same no matter which alternative 

is implemented. There was a 90-day public review and comment period. During this period, 

the Service held public meetings in the eight villages (Hughes, Huslia, Galena, Kaltag, 

Koyukuk, Nulato, Tanana, and Ruby) near the Refuge. A summary of the draft revised Plan 

was mailed to over 1,400 individuals and organizations. The summary announced the comment 

period for the draft revised Plan. 

1.8.6 Prepare and Adopt a Final Plan 

The planning team reviewed and analyzed all of the comments received on the draft revised 

Plan, modified the draft as needed, and developed the final revised Comprehensive Conservation 

Plan. A Finding of No Significant Impact (FONSI) was submitted to the regional director for 

approval and signature. Following approval, a Notice of Availability will be published in the 

Federal Register, and the final revised Plan and FONSI will be distributed to interested parties.

Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 1-17
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1.8.7 Implement Plan, Monitor, and Evaluate 

After the final revised Plan is distributed, the refuge staff will begin implementing any 

management changes called for in the Plan. A critical component of management is 

monitoring—measuring resource and social conditions to make sure that progress is being 

made toward meeting refuge purposes, goals, and objectives. Monitoring includes 

determining if the Refuge is implementing the plan and if actions being taken are effective in 

meeting the objectives. The Refuge will use an adaptive management approach (i.e., 

information gained from monitoring will be used to evaluate and, as needed, modify refuge 

objectives and management direction). 

1.8.8 Review and Revise Plan 

Service policy directs that the Refuge review the Plan annually to assess any need for change 

in management direction. The Refuge will revise the Plan when important new information 

becomes available, when ecological conditions change, or when the need to do so is identified 

during the next review. If major changes are proposed, public meetings may be held and a 

new environmental assessment (or an environmental impact statement) may be needed. 

Consultation with appropriate State agencies and others will occur during any future 

revisions. Full review and revision of the Plan will occur every 15 years or more often if 

deemed necessary. The Refuge will continue to inform and involve the public through the 

appropriate means (such as reporting on activities at annual village meetings and refuge 

update mailings) throughout the implementation and monitoring process. 

1.9 Planning Issues 

The Service defines an issue as any unsettled matter that requires a management decision, 

such as an initiative, opportunity, resource management problem, threat to refuge resources, 

conflict in uses, public concern, or presence of an undesirable resource condition. Issues were 

initially identified by the refuge staff in April 2007. Several other means were used to identify 

issues. We obtained input from the public through a “village leaders” meeting in August 2007, 

at “open houses” in the villages, through issue worksheets that were distributed with the first 

planning update, and through visits with village elders and community leaders. We identified 

eight issues for consideration during revision of the refuge Plan. Some of the issues have 

already been addressed through existing laws, regulations, or policies or are outside the scope 

of the Plan. The remaining issues were addressed through the development of the 

alternatives. The environmental analysis completed for the draft revised Plan discussed the 

effects of implementing each alternative. The following discussion briefly describes each of 

the issues. The Refuge’s role in identifying and analyzing the issues is to objectively consider 

a wide range of approaches that could be taken to address each issue. 

1.9.1 How will the Refuge maintain and manage wildlife populations, especially moose, in 

the face of competition between users and predators? 

The number and range of general comments about moose hunting and salmon fishing 

regulations indicates that this is a major concern of a large proportion of refuge users. Many 

people expressed concern for moose and salmon numbers, the difficulty of getting a moose, 

competition with non-locals for moose and salmon, predation of moose by black bear and wolf, 

1-18 Koyukuk/Nowitna National Wildlife Refuge Revised Comprehensive Conservation Plan 
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the need for changes in both the moose hunting season and the salmon fishing season, and the 

concern for retaining as much of a subsistence lifestyle as is possible in today’s society. 

1.9.2 How will the Refuge address future (off-refuge) mining, oil, and gas development and 

its effect on the refuge environment? 

Local and non-local residents expressed concern for future mining and its affect on the 

environment, especially water quality. There is a fair amount of concern regarding the 

development of future oil and gas leases on and off the Refuge. 

1.9.3 How will the Refuge identify and address contaminants that affect the wild food we 

eat and water quality? 

There are two concerns. (1) Is the food we eat that is gathered from the land contaminated? (2) 

How are off-refuge mining activity and the abandoned Air Force sites affecting water quality 

on the Refuge? 

1.9.4 How will the Refuge monitor and address the effects of climate change? 

This was a general issue brought up in each village we visited during the scoping period. One 

village, Huslia, has been actively discussing climate change for the past five years and working 

with various groups to document it. Climate change is predicted to have far reaching impacts 

on the boreal forests across the world. 

1.9.5 How will the Refuge address maintaining the wild character of the Refuge and 

wilderness quality? 

This concern was shared by local and non-local residents alike. One of the reasons for visiting 

the Refuge is because of its wild character and the experience it offers. Several of the refuge 

users have visited the Koyukuk Wilderness and value the experience they obtained there. 

1.9.6 How will the Refuge address future public use of the Refuge? 

Two areas of concern were expressed regarding future uses of the Refuge. Most of the 

comments focused on the use of all terrain vehicles (ATVs) for recreational use and air boats 

for moose hunting. Concern for future development, such as an interior road system and oil 

and gas exploration, was expressed. 

1.9.7 How can the refuge fire management program help villages address their hazardous 

fuel accumulations? 

People in the villages continue to express concern for adequate wildland fire protection. They 

recognize fire as a necessary natural process but are concerned for the protection of life, 

property, and natural and cultural resources. 

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1.9.8 How will the Refuge address the need for more outreach and better communication 

with the public? 

People in the village expressed the need for more outreach in the schools, sharing of 

refuge Inventory and Monitoring results, and a better understanding of overall refuge 

activities and policies.